Dish EPFD Report 'Tacit Admission' of No Violations: SpaceX

Dish Network can't cite evidence showing SpaceX's pending lower-orbit license modification (see 2007140001) will violate ITU equivalent power flux density limits, so the company instead argues SpaceX's network would do so if it were operated differently, SpaceX said in a docket 20-443 FCC post Wednesday in response to a Dish-commissioned study (see 2102160012). SpaceX said it will operate as laid out under its license terms, not how Dish hypothesizes. It said Dish not citing any actual EPFD limit violations is its own "tacit admission that none exist." Dish Executive Vice President-External and Legislative Affairs Jeff Blum emailed that SpaceX has yet to refute "the premise, methodology, or conclusion of Dish's expert analysis, which is based on SpaceX's own data. Dish's study shows that SpaceX's proposed system in the 12 GHz band would likely violate the EPFD limits adopted by the ITU and the Commission for the protection of [direct broadcast satellite] customers, including the millions of U.S. households served by DISH. SpaceX has been authorized to use 15,000 megahertz of spectrum outside of the 12 GHz band. If the Commission decides to grant SpaceX’s Third Modification, it should exclude the 12 GHz frequencies."